OCC Consults on Information Collection on Home Mortgage Disclosure

CFPB had, on September 07, 2018, issued an interpretive and procedural rule to implement section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act. Section 104(a) amended certain provisions of the HMDA by adding partial exemptions from HMDA's requirements for certain insured depository institutions and insured credit unions. Insured depository institutions and insured credit unions covered by a partial exemption have the option of reporting exempt data fields as long as they report all data fields within any exempt data point, for which they report data.

Section 104(a) of the EGRRCP Act amends HMDA section 304(i), which provides that the requirements of HMDA section 304(b)(5) and (6) shall not apply with respect to closed-end mortgage loans of an insured depository institution or insured credit union if it originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years. Sections 304(b)(5) and (6) do not apply with respect to open-end lines of credit of an insured depository institution or insured credit union if it originated fewer than 500 open-end lines of credit in each of the two preceding calendar years. OCC is soliciting comment on the following questions in light of the section 104(a) changes:

• Whether the collections of information are necessary for the proper performance of the functions of the OCC, including whether the information has practical utility
• The accuracy of the OCC's estimates of the information collection burden
• Ways to enhance the quality, utility, and clarity of the information to be collected
• Ways to minimize the burden of the collection on respondents, including through the use of automated collection techniques or other forms of information technology
• Estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information

Related Link: Federal Register Notice

Comment Due Date: April 15, 2019

Keywords: Americas, US, Banking, HMDA, Regulation C, Mortgage Disclosure, EGRRCP Act, Dodd Frank Act, Information Collection, CFPB, OCC